Policy Assessment & Gap Analysis
- Review of existing AML policies and procedures
- Identification of gaps based on Swiss AML regulations (AMLA, AMLO-FINMA, SRO regulations)
- Benchmarking against best practices in the industry
Our Approach toAML PolicyDevelopment
We follow a structured process to ensure your AML policy is comprehensive, effective, and fully compliant with regulatory obligations in Switzerland.
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Customization & Policy Drafting
- Tailored AML & CTF policies adapted to your business model and risk exposure
- Integration of regulatory requirements, including transaction monitoring, enhanced due diligence, and PEP screening
- Incorporation of Travel Rule compliance and verification procedures for crypto transactions
- Development of risk-based approaches specific to VASPs and financial intermediaries
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Implementation & Compliance Framework Setup
- Development of operational procedures for your first line of defense (e.g., customer onboarding, transaction monitoring)
- Flowcharts and process documentation for compliance teams and developers
- Integration of automation tools and RegTech solutions for compliance efficiency
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Ongoing Review & Compliance Monitoring
- Regular updates to reflect changes in AML laws and regulations
- AML training for employees to ensure proper policy implementation
- Ongoing updates if outsourcing is handled by us, ensuring that policies—especially risk classifications such as FATF country lists—remain fully aligned with the latest regulatory standards
Frequently Asked QuestionsonAMLPolicies
An AML policy is a mandatory requirement for financial intermediaries and Virtual Asset Service Providers (VASPs) operating in Switzerland. It outlines the necessary procedures for detecting, preventing, and reporting money laundering and terrorist financing activities. A well-structured AML policy ensures regulatory compliance and protects businesses from financial and reputational risks.
AML policies should be reviewed at least annually and updated whenever there are significant regulatory changes or operational shifts. For example, when the FATF updates its country classifications, businesses must adjust their risk-based approach accordingly.
At Gecko Compliance AG, we proactively inform our clients about relevant regulatory updates and ensure their AML policies remain aligned with the latest standards. For clients outsourcing compliance to us, we guarantee ongoing updates—not just at issuance—keeping key elements such as risk classifications, country lists, and transaction monitoring frameworks fully up to date.
A comprehensive AML policy should include:
- Customer Due Diligence (CDD) and Know Your Customer (KYC) procedures
- Transaction monitoring and risk-based screening
- Enhanced due diligence (EDD) measures for high-risk customers
- Suspicious activity reporting (SAR) and escalation processes
- Compliance with the Travel Rule for crypto transactions (where applicable)
- FATF country risk classification and sanctions screening
- AML training and awareness programs for employees
- Record-keeping and audit readiness
The Travel Rule mandates that financial intermediaries and VASPs must share identifying information about both senders and recipients of crypto transactions that exceed a defined threshold. Your AML policy should outline:
- Procedures for collecting and verifying customer information
- How your business ensures compliance when dealing with other VASPs or financial institutions
- Technical and procedural solutions for secure data transmission
A risk-based approach (RBA) is crucial in AML policies, as it allows financial institutions and VASPs to focus resources on higher-risk customers and transactions. An effective AML policy includes:
- A risk classification framework based on customer profiles, business activity, and geography
- Ongoing transaction monitoring to detect unusual patterns
- Triggers for enhanced due diligence (EDD) when dealing with high-risk individuals or jurisdictions
Yes, integrating RegTech solutions with your AML policy significantly improves efficiency by automating:
- KYC and onboarding procedures
- Transaction monitoring and risk scoring
- Real-time screening for sanctions, PEPs, and adverse media
- Regulatory reporting and suspicious activity alerts
At Gecko Compliance AG, we help financial intermediaries and VASPs integrate AML compliance tools that streamline processes and ensure seamless regulatory adherence.
Failure to maintain an up-to-date AML policy can result in:
- Regulatory fines and enforcement actions
- Loss of banking relationships or licensing issues
- Reputational damage and operational risks
To avoid such consequences, businesses must regularly update their AML policies and ensure alignment with Swiss AMLA, FINMA, and international FATF standards.
We offer tailored AML policy solutions that include:
✔ Drafting and customizing AML policies to fit your business model
✔ Integrating regulatory requirements, including Travel Rule compliance
✔ Providing operational handbooks and workflow documentation for first-line staff and developers
✔ Continuous monitoring and updates for outsourced compliance clients
Take Control of your AML Compliance
A strong AML policy is essential for regulatory compliance and risk mitigation. Whether you need a new policy, an update, or full compliance outsourcing, we are here to support you.
Contact us today to ensure your AML policy meets all Swiss and international requirements.
Contact us today to ensure your AML policy meets all Swiss and international requirements.